Tibbs v. State’s Empirical Analysis
1991
Citation profile
55 state decisions
How this case has been cited
Cited by 57 later decisions — most recently April 2014 · most notably State v. Bell (1998), Abeokuto v. State (2006)
55 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Martinez v. State · State v. Hall · Dortch v. State
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 57 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"It is not sufficient that an accused merely respond affirmatively to a naked inquiry, either from his lawyer or the court, that he understood that he has a right to a jury trial, that he knows 'what a jury trial is,’ and waives that right 'freely and voluntarily.’ Accordingly, notwithstanding that Tibbs may have had some prior unspecified experience with the criminal justice system, the trial judge could not fairly be satisfied on this record that Tibbs had the requisite knowledge of the nature of the jury trial right, that his waiver of the right was knowing and voluntary, and that the requirements of the rule were thus met. We conclude, therefore, that constitutional due process requirements were transgressed in this case.””
6 later decisions quote this exact passage“[DEFENSE COUNSEL]: And do you understand what a jury trial is? DEFENDANT: Yes, I do. [DEFENSE COUNSEL]: And you indicated to me when I spoke with you at the detention center the other evening that you desired to have the case tried before this Court alone, is that correct? DEFENDANT: Yes, I do. [DEFENSE COUNSEL]: And you do specifically waive your right to have the matter tried before a jury? DEFENDANT: Yes, I do. [DEFENSE COUNSEL]: Has anyone forced you or threatened you to have you give up your right to a jury trial? DEFENDANT: No, they haven't. [DEFENSE COUNSEL]: Have you given up your right to a jury trial freely and voluntarily? DEFENDANT: Yes, I have. * * * [DEFENSE COUNSEL]: Your Honor, I would proffer to the Court that a waiver of a jury trial is freely and voluntarily tendered. * * * THE COURT: All right. [DEFENSE COUNSEL]: And we're ready to proceed, Your Honor. THE COURT: Okay. And Mr. Tibbs enters a plea of not guilty to the four counts, is that right? [DEFENSE COUNSEL]: That's correct. THE COURT: Waives his right to a jury trial? [DEFENSE COUNSEL]: Yes, Your Honor.”
4 later decisions quote this exact passagee.g. Abeokuto v. State · Kang v. State“(a) Generally. In the circuit court a defendant having a right to trial by jury shall be tried by a jury unless the right is waived pursuant to section (b) of this Rule. If the waiver is accepted by the court, the State may not elect a trial by jury- (b) Procedure for Acceptance of Waiver. A defendant may waive the right to a trial by jury at any time before the commencement of trial. The court may not accept the waiver until it determines, after an examination of the defendant on the record in open court conducted by the court, the State’s Attorney, the attorney for the defendant, or any combination thereof, that the waiver is made knowingly and voluntarily.”
4 later decisions quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.